On behalf of ATX
Technologies, Inc., this letter responds to the request of the National
Telecommunications and Information Administration (NTIA) request for comment
regarding the Deployment of Broadband Networks and Advanced Telecommunications
Services.Our comments relate to NTIA’s
request for information regarding the challenges in deploying broadband
services via wireless and satellite networks, specifically the evolution from
analog networks to the digital.We urge
that prior embracing the digital environment; a reasoned transition must evolve
to ensure that fundamental strengths of the Nation’s present wireless network
are preserved.

ATX Technologies, Inc.
(ATX) is a provider of telematics services to automobile manufacturers
(original equipment manufacturers or “OEMs”).The telematics services provided by ATX integrate wireless
communications, location technology, in-vehicle andoff-boardcomputer technology and the availability of live
operators to provide enhanced emergency
response and other needs to individuals who have telematics capability in their
vehicle.At the heart of ATX’s
technology is the ability to automatically notify emergency responders in the
event of a collision, to locate precisely the individual confronted with an
emergency, to communicate with the vehicle and its occupants, to determine the
emergency the individual is facing, to
help accelerate emergency responseto the vehicleand to providepublic safety agencies with critical data about the accident

from in-vehicle sensors and
personal information volunteered by the vehicle owner.

The cornerstone of ATX’s
telematics services is automatic crash notification (“ACN”) and the in-vehicleMayday button, which rely upon analog
cellular networks to simultaneouslytransmit critical data and
open a voice channel between the vehicle and an ATX call center.Similar to the safety benefits provided by
standard factory installation of seat belts and air bags, telematics-based
ACN/Mayday systems represent the latest generation of in-vehicle safety
technology.The ACN service
automatically notifies a private telematics call center, such as ATX’s, that a
vehicle’s air bag or emergency-tensioning restraint has been deployed.Similarly, “Mayday” service signals the call
center when the motorist pushes an in-vehicle emergency call button.Currently, ATX alone has over 300,000
subscribers and receives over 60,000 signals per month from motorists with
telematics-equipped vehicles.There are
over 2 million vehicles on the road today with telematics systems.In addition, ATX and other telematics
service providers offer other, location-based safety-related services such as routing assistance, roadside assistance, real-time traffic reports, real-time tire pressuremonitoring and remote vehicle diagnostics which, to be effective in all potential travel
scenarios, require broad coverage provided by today’s coast-to-coast analog
network.

The automobile and telematics industry,
without government mandate, have committed substantial investment to take
advantage of the full capabilities of the nation’s wireless network to provide
vital information to public safety agencies and enhanced, location-based assistance
to motorists in need.ACN is the kind of life-saving innovation
many contemplated that E911 systems, relying upon the ubiquitous coverage of
the analog network, would make possible.In sharp contrast to the status of government- mandated E911, the
automotive industry has commenced deploying telematics technologies and
equipment that enhance driver safety and greatly assist emergency and medical
personnel in their critical work.This
investment and the benefits that have flowed from it, is an example of how
telecommunications technologies can bring tangible benefit to a range of areas,
in this case, vehicle safety.

How Telematics Technology Developed

Telematics technology was developed
and built around the Advanced Mobile Phone Service (“AMPS”) Analog Cellular
Compatibility Standard (the “Standard”).The Standardadopted by the Federal
Communications Commission (FCC) is currently set forth in the Commission’s
regulations at 47 C.F.R. § 22.901(d).The Standard requires cellular carriers to provide analog cellular
services in compliance with the AMPS standard, so long as there are customers
who subscribe to those analog services.Recently, several, but not all, wireless carriers are advocating
expeditious elimination of the Standard, on the premise that their network
capacity should be devoted solely to a digital format. The FCC has an
outstanding proceeding that is considering the issue.

The AMPS
system was developed to provide a nationwide, single standard, wireless
telephone service.Bandspace was
allocated and wireless carriers were selected to provide that service.To guarantee that the telephones
manufactured and sold could use this service across the country the interested
parties adopted a standard.The FCC, as
part of the authorization to use the bandspace, required that carriers adhere
to this common standard.By allowing a
user to roam the country using the same telephone in all markets, the AMPS
system forms the backbone of the country’s largest single standard, wireless
network. This national framework therefore provides a valuable safety
net (a simple phone call away from help) to anyone traveling virtually anywhere
in the United States.

Since the
AMPs wireless system was similar to terrestrial telephone systems, it could be
used for most the same kinds of things.One of the first was sending digital data from computers over the
system.Since the AMPS system acted in
most ways like the familiar terrestrial telephone system, applications
associated with terrestrial systems could be used over the AMPS cellular
system.Data files could be
exchanged.Computers were linked to
specially adapted AMPS telephones and the data could be sent over the airways.

Telematics
evolved from this environment.Its
critical application in the AMPS environment is the ability to transmit
simultaneously voice and data.With
pervasive redundancy features and the ubiquitous analog network, telematics
allows simultaneous voice communication with
vehicle occupants and transmission of the vehicle’s locationand other data pertaining to a mobile emergencyto be available nationwide
in real-time.

What is emerging in telematics is the capability to
provide on the scene information regarding the type and degree of injury to
vehicle passengers involved in a collision.Based on historical research that examines collisions, place of impact
and resulting injury, sensors embedded in the vehicle are able to determine
where passengers are located in the vehicle, the impact experienced and the
likely injury and transmit this information, through telematics technology to
the hospital emergency room or trauma center.With such information, medical and emergency personnel can not only
determine the response necessary but do so within the golden hour that is so
critical to saving lives. That such capability can soon be a reality is
demonstrated by ATX’s participation in the Commonwealth of Virginia’s
Intelligent Transportation System (ITS) Public Safety Initiative in the Shenandoah
Valley.ATX equipped vehicles are able
to provide emergency responders in the Shenandoah Valley a text version of the
emergency information that otherwise must be conveyed by voice.The text information is relayed in real-time
and allows an immediate response by each authorized agency impacted by the
emergency.

More
broadly, the Standard represents the foundation of the Nation’s wireless
network.The Standard and the
capacity needed to support is the underpinning of the ubiquitous wireless
network that promotes a range of critical public interest elements, from the
ability to communicate across the country, rural, suburban, or urban, to
assisting the hearing impaired, to fulfilling public safety needs through
telematics technologies.Any evolution
from analog to digital must examine how these applications can be replicated in
the digital environment.

THE
DIGITAL NETWORK IS STILL NASCENT AND WILL NOT RELFECT THE CAPACITY AND QUALITY
OF ANALOG FOR THE DISTANT FUTURE

Many do not realize the severe limitations
encompassing data transmission and digital voice technology.Before the AMPS Standard can be eliminated,
including the capacity necessary to support it, the digital environment must be
able to reflect the ubiquitous environment encompassing a range of services
relating to the transmission of voice and data.Not only does the digital environment fall far short of anything
approaching ubiquity, the digital environment is fundamentally voice
directed.The quality, security and
dependability, particularly when attempts are made to integrate data with voice
transmissions, are not present.

Investment in digital data transmission has lagged
considerably behind voice.In ATX’s ACN
service, which all providers of OEM factory-installed
telematics offer, a critical part of bringing emergency assistance to
drivers involved in a collision encompasses an integrated voice/data
capability.As noted, when a collision
occurs, information by way of data is transmitted to the ATX service center.ATX is able to pinpoint the location of the
vehicle to request public safety agency assistance.At the same time, a voice communication is opened over the same
network to determine the degree of help needed.In-vehicle hands-free wireless voice
connection to the vehicle’s passenger enables telematics operators to begin to
gauge the severity of the emergency.

Unlike the analog networks telematics technologies currently
depend on, the digital environment cannot yet match the analog network’s
geographic ubiquity or reliability to transmit voice and data simultaneously.In an emergency situation, it is important
to place a call quickly, affix a location to that call, deliver relevant data
to the correct emergency response agency with jurisdictional authority, and
establish voice communication with the driver.With digital voice systems such integration of voice and data is
possible but has to demonstrate the reliability that is critical in an
emergency circumstance. And the footprint for digital networks does not even
cover half the footprint for today’s analog network.

Contributing further to the challenges faced in the digital
environment in North America, unlike Europe and Japan, is what happens to data
when it passes from one system (e.g. CDMA) to another (e.g. TDMA/GSM).Massive agreements must be in place for this
to work and they are not. The incompatibility of the systems will continue to
pervade for some time to come.

What NTIA Should
Consider

In
analyzing the progress made toward deploying broadband networks and advanced
telecommunications services, and in formulating the Administration’s policies
in this regard, ATX urges NTIA to recognize that any accelerated
movement away from AMPS (including the capacity to support it) without
corresponding advancements in simultaneous voice and data transmission in the
digital world, will actually produce a wireless network that is less robust in
provide location-based safety than what Americans enjoy today. Imagine
explaining to the 2 million customers who now enjoy location-based service in
their vehicles today that it will be able to work in only half the area it is
available today – and that it will be less reliable. A range of enhanced
vehicle safety and securityservices encompassing the transmission of voice and data
information depends upon a ubiquitous network that is not duplicated in the
digital environment.

In examining the
issues surrounding the transition to the digital environment, we urge NTIA to
make clear the important goal reflected in the principles of the Nation’s
communications policy-- a ubiquitous wireless network able to promote the
public safety needs of the American people.This objective translates to ensuring that the many valuable
applications emanating from the AMPs can be replicated in the digital
environment.The record indicates that
AMPS must continue at least until there is a suitable nation-wide substitute.
The complexities, costs and difficulties associated with replicating the analog
environment in the digital format are substantial.ATX urges NTIA to examine closely the transition to digital and
how the digital environment must evolve before any change can take place.Abandoning the AMPS standard without a
reasoned transition would not be in the public interest; it would harm users
and compromise public safety and
homeland security.

This critical transition involves
more than telematics.During this
period of unprecedented threats to national security, the analog network
remains the only nationwide wireless framework that links the country together
in a common communications platform and provides proven location-based safety
and security.The ubiquitous character
and broad potential for a range of technologies and services afforded by analog
must continue to be available.

ATX
commends NTIA for its inquiry into the deployment of broadband networks and
advanced telecommunications and the challenges presented.Please call upon us if we can assist your
review in any way.